Epstein Secrets

ERVICE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by U. S. Mail, postage prepaid, this 2¢ day of June, 2009 to hick A. Goldberger, Esq., 250 Australian Avenue, Suite 1400, West Palm Beach, FL 334101; Bruce E. Reinhart, Esq., 250 Australian Avenue South, Suite 1400, West Palm B

F SERVICE CI HEREBY CERTIFY that a true and correct cop.), of the foregoing has been served I U.S. Mad and Facsmile this ( klay of May, 2009 to: Jack Alan Goldberger, Esq., ... . ---- Aiterbury Goldberger et al., 250 Australian Ave. South, Suite 1400, West Palm Beach, FL 33401. EFTA00180794 I j ROTHSTBIN RO

, & COLEMAN, 515 N. Fiagler Dr. Suite 400, West Palm Beach, Florida 33401. this 11 day of June, 2009. BURMAN, CRITTON, LUTTIER & COLEMAN ATTERBURY, GOLDBERGER & 515 N. Fiagler Dr. Suite 400 WEISS, P.A. West Palm Beach, Florida 33401 250 Australian Avenue South Suite 1400 West Palm Beach, Florida 33401 -c

PALM BEACH COUNTY, FLORIDA CASE NO: 2006CF009454AXX, 2008CF009381AXX STATE, vs. EPSTEIN, JEFFREY D COMES NOW, Intervener, B.B. and file this Response t ndant Jeffrey Epstein's Motion to Stay, and states: In their motion, Defendant asks the Court to stay it. P mg on the production of the NM agre

g was sent by fax and U.S. Mail to the following addressees on this 14th day of September, 2009: Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq. Leo Jack Goldberger, Esq. ss, P.A. Fax: Co-counsel for Defendant Jeffrey Epstein BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Blvd., Suite 400 FL 33401 By:

vin, Esq. (via facsimile w/o enclosures) Jack A. Goldberger, Esq. (via facsimile w/o enclosures) • PHONE: •

of the breach and then move forward with Epstein's prosecution. Accordingly, the undersigned would agree with Epstein's statement at page 4 of its Response, that the fact there exists a Non-Prosecution Agreement does not mean that Epstein is free from future criminal prosecution, and that in fact, "the

ment of particulars of a nonprosecution agreement between Jeffrey Epstein and the U.S. Attorney's Office for Jeffrey Epstein, do attorney Jack Goldberger; attorney for the U.S. Attorney's Office for the Southern The "attorney for the U.S. Attorney's Office for the Southern District of Florida" i

Office for Jeffrey Epstein, do attorney Jack Goldberger; attorney for the U.S. Attorney's Office for

say without applicable exceptions, or based on other evidentiary grounds. Those issues will be argued at the appropriate time. For purposes of this Response, Ms. Maxwell simply notes the fundamental errors in the Notice, failure to comply with the rules, and general principles that make the residual hea

d solicitation offense is a felony. -3- EFTA00179102 pressure against prosecuting the case. The team of attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz.' As explained in the Declaration of Epstein knew of the state investigation by the first week of

attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz.'

he litigant standing to challenge the validity of that subpoena." In re Grand Jury, Ill F.3d 1066, 1073 (3d Cir. 1997)(collecting On page 38 of its Response, the government finally admits what it is looking for: evidence of sexual exploitation of minors, including surveillance camera footage, "computer p

was prepared to name as a victim of an enumerated offense. • d t Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300. P

laim against Jeffrey Epstein, his attorney, Jack Goldberger, asks that you contact him at Atterbury Goldberge

On July 7, 2008, the Court directed the Government to file a response to the Petition by July 9, 2008, at 5:00 p.m. The Government has prepared its Response, which is attached as Exhibit A, and the Declaration of Assistant United States Attorney A. Marie Villafana, as well as correspondence with several

r cases were still under investigation. Tr. July I I, 2008 at 4-6, 18-19, 22-23. 42. On June 30, 2008, the U.S. Attorney's Office sent an e-mail to Jack Goldberger, criminal defense counsel for Epstein, reflecting continuing efforts to keep the NPA secret: 19 EFTA00177027 Case 9:08-cv-80736-KAM Document 48

the U.S. Attorney's Office sent an e-mail to Jack Goldberger, criminal defense counsel for Epstein, reflectin

(DE1 at 1-2.) On the same day, the government was ordered by the Court to respond. (DE3). Two days later, on July 9, 2008, the Government filed its Response and an accompanying Declaration, establishing that (I) no federal criminal case charging Epstein had ever been filed and that a non- prosecution agr